ADB 76-8 — Pipeline Safety Interpretation

Page 1Advisory Bulletin No. 76-8 August, 1976 _ Relates to 49 CFR, Part 192 FEDERAL GAS PIPELINE SAFETY STANDARDS AMENDED FOR OFFSHORE FACILITIES...On August 9, 1976, the Materials Transportation Bureau (MTB) issued an amendment to the Federal gas pipeline safety standards to modify many of the design, construction, testing, operation, and maintenance regulations in 49 CFR Part 192 as they relate to gas pipeline facilities and the transportation of gas offshore in or affecting interstate or foreign commerce. The amendment also enlarges the scope of Part 192 by deleting the exemption in Section 192.1 for certain rural gathering lines located offshore. The regulations will apply to the offshore gathering of gas downstream from the outlet flange of each facility on the outer continental shelf where hydrocarbons are produced or where produced hydrocarbons are first separated, dehydrated, or otherwise processed, whichever facility is farther downstream. Purpose of the amendment is to more clearly delineate the applicability of Part 192 to offshore gas pipelines and to better assure the safe operation of those pipelines. New or amended provisions cover offshore facilities as they relate to sections on scope of part, definitions, class locations, general provisions, design factor for steel pipe, support and anchors, design and construction of compressor stations, emergency shutdown of compressor stations, transmission line valves--repair or removal of defects, protection from hazards, installation of pipe in a ditch, cover over buried transmission line, external corrosion control monitoring, external corrosion control test stations, atmospheric corrosion control monitoring, maximum allowable operating pressure for steel or plastic pipelines, transmission lines--leakage surveys, transmission lines--permanent field repair of imperfections and damages and permanent field repair of leaks, and abandonment or inactivation of facilities. The amended regulations generally become effective on November 1, 1976. However, additional lead time to August 1, 1977, is provided for certain sections identified in the amendment. Reprints of Amendment 192-27, Docket No. OPS-30 (41 Fed. Reg. 34598, August 16, 1976), are being sent to those parties on the appropriate OPSO mailing lists. Relates to 49 CFR, Part 195 dal\192\227\76-08 1#

Page 2FEDERAL PIPELINE SAFETY STANDARDS FOR OFFSHORE LIQUID PIPELINES AMENDED...On August 9, 1976, the MTB issued an amendment to the Federal liquid pipeline safety standards, particularly as they apply to offshore pipeline facilities. The amendment modifies many of the design, construction, testing, operation, and maintenance regulations in 49 CFR Part 195 as they relate to offshore transportation by pipeline in interstate or foreign commerce of hazardous materials, petroleum, or petroleum products. It also enlarges the scope of Part 195 by deleting the exemption in Section 195.1(b)(4) for rural gathering lines located offshore. Regulations will apply to transportation in offshore pipelines which are located downstream from the outlet flange of each facility on the outer continental shelf where hydrocarbons are produced or where produced hydrocarbons are first separated, dehydrated, or otherwise processed, whichever facility is farther downstream. The purpose of the amendment is to more clearly delineate the applicability of Part 195 to offshore liquid pipelines and to better assure the safe operation of those pipelines. In accordance with Section 8(a) of the Deepwater Port Act of 1974 (33 USC 1507 (a)), the offshore pipelines subject to the regulations in Part 195 and this amendment include the pipeline facilities which are part of a deepwater port. Most of the amendments pertain to steel pipelines which are the ones commonly used offshore. Provisions of the amendment cover offshore liquid pipeline facilities in the specific subject areas of scope, internal design pressure, welds--repair of defects, welds-- nondestructive testing and retention of testing records, external coating, cathodic protection system, installation of pipe in a ditch, cover over buried pipeline, valves--general, valves--location, test medium, general requirements, and cathodic protection. The amendments become effective on November 1, 1976, except that additional lead time to August 1, 1977, is provided for specific sections. Reprints of Amendment 195-11, Docket No. OPSO-35 (41 Fed. Reg. 34035, August 12, 1976), are being sent to those parties on the appropriate OPSO mailing lists. Relates to 49 CFR, Part 195 DOT AUGMENTS SAFETY MONITORING ACTIVITIES ON THE TRANS-ALASKA PIPELINE SYSTEM...In recent weeks, the Department of Transportation (DOT) and its MTB and OPSO have taken several actions with regard to the monitoring of construction work on the Trans-Alaska Pipeline System. Early in July, Deputy Secretary of Transportation John W. Barnum announced the following courses of action: (1) To identify all the girth welds that do not meet the prescribed DOT standards, to have the irregularities corrected, and to assure that the remainder of the construction work is carefully monitored to prevent any recurrence of the problem; (2) Alyeska Pipeline Service Company has been directed to furnish DOT a plan and a schedule for correcting all welding deficiencies, actions which will be verified to assure compliance; (3) Retired Coast Guard Rear Admiral Joseph Steele was named to head an onsite DOT task force to monitor pipeline progress during the balance of the 1976 construction season; (4) Two members of the DOT's Office of Pipeline Safety Operations are conducting onsite overall dal\192\227\76-08 2#

Page 3surveillance; and (5) Five additional DOT welding experts were sent to inspect welding and radiography of girth welds. The Deputy Secretary of DOT, along with representatives of other concerned Federal agencies, conducted an onsite inspection of the Trans-Alaska Pipeline System in July to further assess the situation and to consider new pipeline testing methods. Relates to 49 CFR, Part 195 DOT PERSONNEL TESTIFY BEFORE HOUSE AND SENATE COMMITTEES ON ALASKA WELDING PROBLEMS...DOT, MTB, and OPSO personnel recently testified before two Congressional Committees on matters relating to the Trans-Alaska pipeline. On June 21, Deputy Secretary of Transportation John W. Barnum, MTB Director James T. Curtis, Jr., OPSO Acting Director Cesar DeLeon, and Lance Heverly and Lloyd Ulrich of the OPSO staff testified before the Subcommittee on Energy and Power of the House Committee on Interstate and Foreign Commerce. Testimony covered various matters about the construction of the oil pipeline being built in Alaska by the Alyeska Pipeline Service Company. The areas of greatest concern to the Subcommittee were those related to girth welds, weld inspection, recordkeeping of the welding and weld inspection program, quality control and quality assurance programs of the pipeline, and other matters related to assuring that the completed pipeline would meet the Federal pipeline safety standards contained in 49 CFR Part 195. On July 21, Deputy Secretary John W. Barnum and MTB Director James T. Curtis, Jr., appeared before the Senate Interior and Insular Affairs Committee to testify concerning the construction of the Trans-Alaska Pipeline System. Specific topics covered in the testimony included the background of the Trans-Alaska construction developments, OPSO monitoring of construction activities, relationship of DOT monitoring activities with those of other Federal agencies, studies of stress design levels on the Alyeska pipeline, welding and weld inspection matters, current welding problems and DOT's actions toward solving them, radiography of the pipeline welds, additional methods of verifying the quality of the welds which are now being considered, and the current DOT monitoring activities onsite in Alaska. Relates to 49 CFR, §195.212 and Subpart D WAIVER ISSUED TO ALYESKA ON BENDING REQUIREMENTS; NOTICE OF ANTICIPATED PETITION FOR WAIVERS ON ALYESKA ALSO PUBLISHED...On August 3, 1976, the MTB issued a waiver to Alyeska Pipeline Service Company from compliance with the requirement in Section 195.212 which provides that for each field bend of steel pipe containing a longitudinal welds, "the longitudinal weld must be as near as practicable to the neutral axis of the bend." In consideration of all available information, MTB found that under dal\192\227\76-08 3#

Page 4present pipeline technology, there is little, if any, risk of pipe damage from placing a longitudinal seam in a position other than near the neutral axis during bending. Accordingly, the waiver from 49 CFR 195.212 was granted subject to the following conditions: (1) All bends must be made using an internal bending mandrel, and (2) Alyeska shall report all unacceptable seam damage due to bending and bend failures during testing to MTB. Because of the significance of the findings, in the near future MTB will issue a notice of proposed rule making to modify the general requirement in 49 CFR 195.212(b)(3) consistent therewith. On August 12, 1976, the OPSO issued a notice (Docket No. 76-12W) concerning the Trans- Alaska pipeline--anticipated petition for waivers. Alyeska Pipeline Service Company has advised the DOT that it expects to petition the MTB for waivers to allow girth weld defects or arc burns greater than allowed by 49 CFR Part 195, Subpart D, on the basis of a fracture mechanics concept. The anticipated petition(s) and the proceedings thereon may raise issues that require analysis of interrelated technical problems. The notice was published to bring the nature of those problems to the attention of interested Federal and State agencies and other interested persons at the earliest practicable time. In consideration of the nature and number of possible weld defects to be addressed, the notice also sets forth requirements covering preliminary determination of the information and data required for processing any request for a waiver. Persons planning to file comments on Docket No. 76-12W or on the anticipated petition(s) who wish to be served with copies of future notices issued by the OPSO in this matter, may file a request to be placed on the Notice Mailing List for that Docket with the Docket Clerk at the Office of Pipeline Safety Operations, Department of Transportation, Washington, D.C. 20590. All comments received will be considered and will be made available in the docket for public inspection along with the petition(s) and related analyses for public inspection upon receipt. Reprints of the waiver, Docket No. Pet. 76-11W (41 Fed. Reg. 34103, August 12, 1976), and of the Notice, Docket No. 76-12W (41 Fed. Reg. 34375, August 13, 1976), were sent to those parties on the Associations and Publications mailing lists. BAILEY NAMED NTSB MEMBER...Miss Kay Bailey, a former Texas legislator and one-time aide to Anne Armstrong, the U.S. Ambassador to Britain, has been sworn in as a member of the National Transportation Safety Board (NTSB). Bailey, who is a lawyer and a former television news correspondent, will serve as Vice Chairman of the Board for the first two years of her five- year term. A Republican, Miss Bailey was elected to the Texas House of Representatives in 1972. She was reelected in 1974, and was seeking a third term when President Ford nominated her to replace Isabel A. Burgess whose NTSB term expired December 31, 1974. Miss Bailey's legislative work centered on transportation. She cosponsored a bill to reorganize the Texas Highway Department and to create a mass transit authority for Houston, Texas. She also was appointed to the dal\192\227\76-08 4#

Page 5Transportation Task Force of the National Legislative Conference. The Conference studied problems of railroads, highways, airports, and the trucking industry. Miss Bailey, 32, was born in Galveston, Texas. She attended the University of Texas and the University of Texas School of Law, receiving an LL.B. in 1967. She was admitted to the Texas State Bar in 1967. From 1969 to 1971, Bailey was a political correspondent for television station KPRC, Houston, the first woman to hold the job. She also has been in the private practice of law with the firm of Reynolds, White, Allen, and Cook. TWO-DAY GAS INDUSTRY SAFETY SEMINARS SCHEDULED...Ten additional 2-day seminars, "Safety Requirements for Gas Pipeline Systems," have been scheduled for the remainder of the year: September 8-9, 1976 Wisconsin September 27-28, 1976 Louisiana Sept. 30-Oct. 1, 1976 Louisiana October 18-19, 1976 Texas October 21-22, 1976 Texas October 27-28, 1976 Ohio November 29-30, 1976 Pennsylvania December 2-3, 1976 Pennsylvania December 15-16, 1976 North Carolina December 20-21, 1976 O P E N Questions concerning the scheduling of future 2-day gas industry safety seminars should be addressed to the Chief, State Programs Division, OPSO. Persons interested in attending any of the above scheduled seminars should contact their appropriate State agency for details. Seminars have substantial emphasis on cathodic protection and gas failure investigation, particularly as they relate to operators of smaller gas systems. STATE PARTICIPATION IN OPSO GAS PIPELINE SAFETY PROGRAM REACHES 100 PERCENT...For the first time since the OPSO gas pipeline safety program was established in the DOT in 1968, the program now includes all 50 States and the District of Columbia and Puerto Rico. The most recent State to affiliate with the national gas pipeline safety program was New Jersey. The Board of Public Utility Commissioners has signed a 5(b) agreement with OPSO and expects to participate along with 45 other States in the Federal grant-in-aid program for 1977. PROCEDURAL GUIDE FOR GRANT-IN-AID PROGRAM... A new Procedural Guide has been developed by OPSO to assist State agencies in applying for and administering grant-in-aid dal\192\227\76-08 5#

Page 6funds. This Guide, which is designed to simplify the pipeline safety grant program, will be distributed with the grant application material this month. Relates to 49 CFR, §192.223, §192.227, and §192.229 INTERPRETATION OF REGULATIONS Question: Must a welder who qualified under 49 CFR 192.227(a)(2) by making a 12-inch butt weld and 12-inch inverted tee test have a butt weld and a fillet weld cut out to verify his qualifications under Section 192.227(c)(2)(i)? OPSO Interpretation:..."As provided by Section 192.223(b), each welder must perform a qualifying test for the welding procedure to be used. When a welder qualifies under Section 192.227 (a)(2), to maintain the qualification, Section 192.229(c) requires that within the preceding six calendar months, the welder must have had at least one weld tested and found acceptable under either Section 3 or 6 of API Standard 1104. Section 192.227(c)(2)(i) requires that a production weld be cut out, tested, and found acceptable in accordance with the qualifying test only if a welder qualifies under Section 192.227(c). "When a welder initially qualifies for more than one welding procedure, to maintain the qualification for a particular procedure, the welder must have a weld using that procedure tested, and found acceptable. A welder need not maintain the qualifications for all the procedures for which the welder initially qualifies in order to weld under a single procedure." \signed\ Cesar DeLeon Acting Director Office of Pipeline Safety Operations dal\192\227\76-08 6#

Page 7The Secretary of Transportation has determined that publication of this periodical is necessary in the transaction of the public business required by law of this Department. Use of funds for printing this periodical has been approved by the Director of the Office of Management and Budget through November 30, 1976. dal\192\227\76-08 7#